Books

EXCHANGE OF INFORMATION TAX ASSESSMENTS: Practical Considerations

Authors: Piergiorgio Valente and Luigi Vinciguerra The use of artificial structures or “constructions” and the exploitation of “disharmony” existing between national laws have the effect of exacerbating the loss of tax revenue. The fight against tax evasion and aggressive tax…

HIDDEN PERMANENT ESTABLISHMENT TAX ASSESSMENTS: Practical Considerations

Authors: Piergiorgio Valente and Luigi Vinciguerra Non-resident foreign entities producing corporate income on Italian territory may register as permanent establishments (thus becoming fully subject to taxation in Italy) or may take a series of actions leading to the creation of…

COMPARABILITY ANALYSIS IN TRANSFER PRICING: Application Methods

Authors: Piergiorgio Valente, Antonella della Rovere and Pietro Schipani The possibility that related companies belonging to the same multinational Group may pursue policies aimed at affecting transfer prices has prompted supranational bodies to draft a series of guidelines concerning the…

CORPORATE TAX RESIDENCE AND TAX AVOIDANCE (3rd Ed.)

Author: Piergiorgio Valente This volume provides a detailed analysis of the issues of companies’ tax residence and fictitious foreign residence by offering normative, interpretative, and case-law references and assessing the impact of parent companies’ leadership and coordination activities. The book…

INTERNATIONAL TAX TREATIES (6th Ed.)

Author: Piergiorgio Valente Bilateral treaties against double taxation represent a topical theme for current and future international tax scenarios. Within a global competitive arena, the safeguard of income flows by the Tax Authorities assumes a particularly significant role as to…